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Take Two: En Banc Eleventh Circuit to Address Whether a Single Text Message Can Confer Standing Under TCPA

As discussed here, on July 27, 2022, the Eleventh Circuit Court of Appeals sua sponte vacated the district court’s approval of a $35 million class-action settlement in Drazen and Godaddy.com, LLC (Godaddy) v. Pinto. Although...more

The CFPB and FTC Continue to Focus on Tenant Screening

On February 28, the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) jointly issued a Request for Information, seeking public comment on how background screening affects individuals seeking...more

Supreme Court to Hear CFPB Funding Case

This morning the U.S. Supreme Court granted the Consumer Financial Protection Bureau’s (CFPB or Bureau) petition for certiorari in Community Financial Services Association of America Ltd. (CFSA) v. CFPB, a case that could...more

TransUnion In “Active Settlement Discussions” with CFPB and FTC Over Tenant Screening

On February 14, TransUnion filed its annual 10-K report pursuant to the Securities and Exchange Act. Under the section entitled “Risks Related to Laws, Regulations and Government Oversight,” the company disclosed that it was...more

2022 Year in Review and Look Ahead Crossover With FCRA Focus - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis in this inaugural crossover episode with Partner Dave Gettings of FCRA Focus in welcoming their guests and fellow Partners Cindy Hanson and David Anthony. Dave,...more

2022 Year in Review and Look Ahead Crossover With The Consumer Finance Podcast - FCRA Focus [Audio]

Please join Consumer Financial Services Partner Dave Gettings in this inaugural crossover episode with Partner Chris Willis of The Consumer Finance Podcast in welcoming their guests and fellow Partners Cindy Hanson and David...more

Community Financial Services Association of America Files Opposition to Certiorari and Cross Petition for Certiorari

As discussed here, on October 19, 2022 the Fifth Circuit Court of Appeals in Community Financial Services Association of America Ltd. (CFSA) v. Consumer Financial Protection Bureau (CFPB) held that the CFPB’s funding...more

Second Circuit Holds No FCRA Violation When Dischargeability of Debt is a Legal Question

Should credit reporting agencies (CRAs) be held liable under the Fair Credit Reporting Act (FCRA) for alleged reporting inaccuracies that turn on legal disputes? According to the Second Circuit in a recent decision, the...more

CFPB’s Involvement in Tenant Screening - FCRA Focus Podcast [Audio]

Please join Consumer Financial Services Partner Dave Gettings and his fellow Partner Ron Raether as they discuss the Consumer Financial Protection Bureau and its supervision of the tenant screening industry. During this...more

CFPB Highlights Purported “Problems With Tenant Background Checks”

On November 15, the Consumer Financial Protection Bureau (CFPB) issued two reports, highlighting what the CFPB perceives to be forms of errors that frequently occur in tenant background checks and the impacts the CFPB...more

Ninth Circuit Affirms Award of Attorneys’ Fees in FDCPA Matter

In Hanrahan v. Statewide Collection, Inc., No. 21-16187 (9th Cir. Sep. 1, 2022), the Ninth Circuit affirmed an award of attorneys’ fees in favor of the plaintiff in an action brought under the Fair Debt Collections Practices...more

CFPB Warns CRAs and Furnishers of FCRA Liability for Failing to Conduct Proper Investigations

On November 10, the Consumer Financial Protection Bureau (CFPB) published a circular, stating that both consumer reporting agencies (CRAs) and furnishers may be held liable under the Fair Credit Reporting Act (FCRA) for...more

An Inside Look as a Juror - FCRA Focus Podcast [Audio]

Please join Consumer Financial Services Partner Dave Gettings and his guests and colleagues Jessica Lohr and Virginia Flynn who discuss their recent service as jurors on criminal cases, while also providing valuable insight...more

Third Circuit Hands Down Decision in FCRA Pay Status Cases - FCRA Focus Podcast [Audio]

Please join Consumer Financial Services Partner Dave Gettings and his colleagues Ethan Ostroff, Brooke Conkle, and Jon Kenney as they discuss the Third Circuit’s recent decision in the Bibbs case, particularly the Third...more

Court Grants Debt Collector Summary Judgment in FDCPA Claim Based on Collection Letter With Multiple Addresses

In Bacalzo v. Credit Control, LLC, No. 20-16904 (KMW/MJS) (D.N.J. June 7, 2022), the court granted summary judgment in favor of a debt collector who included multiple contact addresses in a debt collection letter....more

Court Denies Motion to Dismiss FDCPA Suit Based on Pleadings Statements of a Previous Lawsuit

In Louis v. Deshmukh, Civil Action No. 21-19902 (D.N.J. July 27, 2022), the District of New Jersey denied a motion to dismiss a putative class action, asserting claims under the Fair Debt Collections Practices Act (FDCPA)...more

Third Circuit Adopts “Reasonable Reader” Standard for Evaluating Whether a Credit Report Is Inaccurate or Misleading

What standard should courts use to determine whether information contained in a consumer’s credit report is inaccurate or misleading? According to the Third Circuit in a recent precedential decision, the standard should be...more

CFPB’s Increasingly Active Interest in Credit Reporting - FCRA Focus Podcast [Audio]

Please join Consumer Financial Services Partner Dave Gettings and his fellow Partner Ethan Ostroff as they discuss the Consumer Financial Protection Bureau’s increasingly active interest in credit reporting, including a...more

Recent Trends in Class-Action Consumer Finance Litigation - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis and his guests and colleagues Dave Gettings and Mary Kate Kamka as they discuss recent trends in class-action consumer finance litigation, including: -The...more

Court Finds Entity Partnering With Medical Provider Does Not Qualify as a Debt Collector Under the FDCPA

In Palacio v. Med. Fin. Sols., No. 21 CV 1288 (N.D. Ill. June 14, 2022), the court granted summary judgment in favor of the defendant, finding that it did not qualify as a “debt collector” under the Fair Debt Collections...more

District Court Applies TCPA “Established Business Relationship” Exception to Permit Customer Calls After Contract Termination

On July 18, a New Jersey district court ruled that a customer’s contract termination with a merchant does not also terminate the “established business relationship” (EBR) exception for purposes of the Telephone Consumer...more

A Conversation with Kristi Kelly of Kelly Guzzo - FCRA Focus Podcast [Audio]

Join Consumer Financial Services Partner Dave Gettings as he hosts guest Kristi Kelly, one of the founders of Kelly Guzzo PLC, for a conversation discussing current FCRA trends from the plaintiffs’ counsel perspective. As a...more

An Industry Perspective: A Conversation with Eric Ellman of the Consumer Data Industry Association - FCRA Focus Podcast [Audio]

Please join Troutman Pepper Partner Dave Gettings and his guest, Eric Ellman, of the Consumer Data Industry Association, for a conversation regarding recent industry developments in credit reporting. Dave and Eric discuss the...more

Court Grants Partial Summary Judgment in FCRA Case Based on Statute of Limitations

In Fowler v. Preferred Collection & Mgmt. Servs., No. 8:21-cv-1038-WFJ-AAS (M.D. Fla. May 16, 2022), the court granted in part and denied in part the defendant’s motion for summary judgement as to claims asserted against it...more

Court Reduces Punitive Damages Award in FCRA Case

In Ramones v. AR Res., Inc., No. 19-62949-CIV-SCOLA/SEITZ (S.D. Fla. Apr. 8, 2022), the court refused to set aside an award of punitive damages based on violations of the Fair Credit Reporting Act, but it reduced the jury’s...more

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